IR 05000312/1985022

Insp Rept 50-312/85-22 on 850812-16.No Violation or Deviation Noted.Major Areas Inspected:Licensee Compliance W/Requirements of 10CFR50,App R & Fire Protection Program

ML20135B324
Person / Time
Site:	Rancho Seco
Issue date:	08/27/1985
From:	Qualls P, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20135B317	List: IR 05000312/1985022 ML20135B315
References
50-312-85-22, TAC-53444, NUDOCS 8509100524
Download: ML20135B324 (11)

Text

{{#Wiki_filter:_ _ _ _ _ - _ _ _ . . _ - - _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ _ .

   .
. ,

U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/85-22 License No. DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Unit I-Inspection at: Herald, California (Rancho Seco Site) Inspection Conducted: August 12-16, 1985 Inspectors: M P. ualIs, eactor Inspecto

               '

8[47/85' Date Signed Approved by: - - "M T' Young Jr. , pief, E npringSection Date Signed , Summary: .'., .~, Inspection during the period of August 12-16, 1985 (Report No. 50-312/85-22) Areas Inspected: This announced inspection corisisted of an inspection of licensee compliance with the requirements of 10,CFR 50 Appendix.-R and the fire protection program. The inspection involved a total of 183 hours onsite by one NRC inspector, 2 NRR system reviewers and 2 BNL consultants.. This ~ inspection involved activities covered ^in Temporary, Instruction ~2515/62 Rev. 2 which covers inspection procedures 37700,1 37701, 41700,'42700,"64704, 72701 '

              -
              * i and 30,70 .
               - .
             ,, ,

Results: Of the areas inspected no7 violations *or deviations were identified.

, , e

                 >
               .

m 's

                  '

1-

                 ,

u- 'i r fi,

                 .
              ,, , '
                .
               ,; t>.
                 *

i 8509100524 850027 PDR ADOCK 05000312 PM s-G <

                     ,
-     e         ,

s ,

               , -
                , +,d,,y,  , . - ,   ,-u -

.
.

DETAILS Persons Contacted

 *R. Rodriguez, SMUD, Assistant General Manager, Nuclear
 *P. Oubre, SMUD, Manager, Nuclear Operations
 *W. Spencer, SMUD, Plant Operations Supervisor
 *L. Schwieger, SMUD, Manager, Quality Assurance
 *L. Keilman, SMUD,. Manager, Nuclear Engineering
 *R. Dieterich, SMUD, Licensing Supervisor
 *R. Daniels, SMUD, Supervisor, Electrical Engineer
 *J. Field, SMUD, Technical Support Superintendent
 *J. McColligan, SMUD, Nuclear Project Engineer '
 * Arata, SMUD, Safety / Fire Protection Specialist
 *R. White, SMUD, Electrical Engineer
 *T. Singh, SMUD, Associate Electrical Engineer ..
 *A. Singh, NRC/NRR/DSI/ASB, Auxiliary Systems Engineer
 *S. West, NRC/NRR/DE/CMEB, Fire Protectio'n Engineer
 *P. Qualls, NRC, Reactor Inspector ,
 '*K. Parkinson, BNL/NRC, Electrical Inspector-
 *A. Coppola, BNL/NRC, Systems' Reviewer: ,

      -
 *G. Perez, NRC, Resident Ins'pector  - ,
 *J. Eckhardt, NRC, Sr. Resident Inspecto ,,  ,
 *S. Kammer, UESC, Lead Engineer  ' "
 *L. Young,.UESC, Lead Licensing Engineer
 *K. Scown, Impell, Section Manager-  ' '
 *U. Witte, Impell, Senior Engineer *
     ,
 * Whitsett, Impell, Senior Enginee * r
 * Payne, Impell, Principal Engineer
 * Powell, Impell, Supervising Enginee,r .  -
      .
 * Kolinger, Impell, PrincipaliEngineer #  -
 * Kleinsorg,'Impell, Supervising Engineer  *
 *C. Robinson, Impell,' Principal Engineer
 *S. Wallsen, Impell, Senior Engineer
 *J. Hall, Impell,' Engineer
'
 *J. Campbell, Impell, Engineer
'N  ,. *B.. Harrison, Impell, Senior Engineer
.  *J. Saleeby, Impell, Engineer
 *M. Kermani, Bechtel, Civil Engineer
 '
 !'y*B. Leon, Bechtel, Engineer T. Chalian, Bechtel, Electrical Engineer I. Mathur, Bechtel, Electrical Engineer P..Hatago, Bechtel, Electrical Group Supervisor R. Gupts, Bechtel, Electrical Engineer G..Lalwani, Bechtel, Electrical Engineer t
; 1
 )
 * Denotes personnel at the exit meetin .c. t
,j'

_ In addition.* numerous other members of licensee or contractor staff were

 ,

contacte x9 i

  ,.
  ,

   . . .  .
    ,
   .  .
.
      ;
'

    ' .
    , 's
   *   * <
     .
   ,

i 2 . NRR Review Items .

      <
   ..>

The following concerns were identified by.the< inspection team. These concerns had been identified by the. licensee.to the NRR; project manager (PM). The inspection team discussed with the PM,how he had previously

    ~

told the licensee to resolve these iss'ues as noted'below:'

   "
      ... The licensee recently completed revising and updating his Fire Hazards Analysis (FHA). In this process the licensee changed fire area boundaries. The licensee determined that he could decrease the number of fire areas by incorporating several smaller areas into a number of larger areas. As a result, there are now a number of fire areas that do not have area wide suppression and/or detection as required by Appendix R. The PM had stated that no exemption request

was required because these changes would be reviewed when the updated FHA was reviewed'and addressed in a Safety Evaluation Report (SER). A number of fire barriers in the plant have penetrations through them which are not fire rated. An analysis was performed for each to determine its applicability. Appendix R requires that penetrations be rated at the same rating as the barrier that they pass through. These penetrations were analyzed and are listed in the FHA. The PM said that no exemption request was needed because this would be inspected during the FHA review'and addressed in a SE The Auxiliary Feed' Water (AFW) Pump separation exemption request states that a deluge ~ system will be installed to protect the AFW pumps and prevent both pumps from being disabled by a single fir The PM had accepted a March 1986 date to complete installation of the deluge system and required-the licensee to conduct hourly fire watch inspections of the are The requirement to have the Boric Acid pumps for cold shutdown had not yet been determined. If they are required they will be needed only after 130 full power operating days from the next startup. The PM had given the licensee until November 1, 1985 to determine that the Boric Acid pump is not needed'to maintain cold shutdown or to have a repair procedure in place to accomplish'a repair of the pumps. November 1,.1985 was well within 130 days from their next startu Due to some statements made by NRR when denying a previous exemption request, the licensee discussions with the PM had indicated that no exemption request was needed concerning the lack of a suppression system'in the control room. The inspection team felt that.an exemption was needed for this area and the licensee committed to submit one. The draft exemption request was prepared while the team was on the sit No violations or deviations were identifie ,m L 4 \

^^ - -- 1  3

  -
.
-

3 - 3. Outstanding Exemption Requests In accordance with 10 CFR 50.48 licensees may request exemption from meeting Appendix R requirements in areas where they have taken equivalent fire protection measures. NRR evaluates these exemption requests on a case-by-case basis to determine their acceptability. The licensee had the following exemption requests submitted for NRR review. During the inspection, the NRR reviewers examined the proposed exemption requests and the fire areas for which they apply. They identified no additional concerns with these requests. However, the following items are open pending formal review of the exemption requests by NR Fire Area 69, separation of Auxiliary Feedwater Pumps, requested February 28, 1985 (85-22-01) Fire Area 69, Auxiliary Feedwater Valves do not have required suppression and detection, requested February 28, 1985 (85-22-02) Fire Area 68, Cables inside containment electrical penetration area, requested February 28, 1985 (85-22-03) Fire Area 69, Nuclear Service Cooling Water Pumps, requested May 24, 1985 (85-22-04) Fire Area RGI, cables inside auxiliary building electrical penetration area, requested February 28, 1985 (85-22-05) Fire Area RBI, Auxility Building mechanical penetration area, requested February 28, 1985 (85-22-06) hour cold shutdown requirement, requested February 28, 1985 (85-22-07) Fire Area 110 NSRW pumps, requested February 28, 1985 (85-22-08) Fire Area 91, 'NSEB roof, requested April 4, 1985 (85-22-09) Fire Area 74, Auxiliary Building roof, control room HVAC unit separation, requested May 24,.1985 (85-22-M) Fire Area 74, Auxiliary Building roof, Nuclear Service cooling water surge tank level switches, requested May 24, 1985 (85-22-11) Control Room, the licensee committed to submit to NRR for review an exemption request concerning the lack of a -fire suppression system in the control room. This had not been submitted due to a misunderstanding with NRR (85-22-12) (see paragraph 2.e of this report). Fire Area 68,-Reactor Coolant Pump' Lube Oil-Collection System, tank capacity, requested February:28, 1985 (85-22-13) _

   ,

No violations or deviations were identified

  -
   - .a ,
     ,

i e ,.- * .

   -
    .
.     .

4 Facility Design - 10 CFR 50 Appendix R Compliance The licensee is required to meet the technical requirements of Appendix R to 10 CFR 50 in the facility's~ design as required by 10 CFR 50.48. The Appendix R criteria specified, requires that the fire protection features provided in the. facility's design be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or remote shutdown station be free of fire damage. Systems necessary to achieve and maintain cold shutdown conditions are required to be repairable in order to achieve cold shutdown within 72 hours from either the control room or remote shutdown statio A collective assessment of selected areas containing structures, systems

.and components important to safe shutdown was made by the inspection team. The following conclusions were ascertained: Compliance with Section III.G.2 and III. The Rancho Seco electrical distribution system was inspected to verify.. compliance with Appendix R.III.G.2 and 3 requirements. This inspection was performed on a sample of components and circuits and verified by in plant walkdown of wiring, conduits and raceways. No conditions were identified that did not conform to Appendix R requirements except as previously identified by Appendix R exemption request No violations or deviations were identifie Common Bus Concern A sample of Rancho Seco circuits were evaluated to verify that circuit coordination satisfied the common bus concern. Of the areas examined, no discrepancies were identifie No violations or deviations were identifie Spurious Signal Concern Spurious signal concerns were evaluated to determine if a fire in an area could prevent operation or cause maloperation of redundant trains of safe shutdown equipment located in the same fire are Rancho Seco has provided switches, optical isolators and multiplexers to provide satisfactory isolation of circuits and equipment. Of the areas examined no discrepancies were identifie No violations or deviations were identifie ,
- High-Low Pressure Interface
    '

High-Low pressure interface. concerns at Rancho Seco are resolved by procedurally isolating components causing the potential proble For example, the pressurizer relief valve and blocking valve are

   *
    . <
   't -
   -

O t , ,

    * *

ls /

    *
     .
     -
     ,
     *

__ . . . - . .

     -
 .
'

S

% kept closed by de-energizing the respective actuators. Of the areas examined no discrepancies were'noted.

J No violations or deviations were identifie High Impedance Faults An analysis performed b'y Rancho Seco demonstrated to the inspectors that high impedance faults would not result in loss of required safe shutdown circuits. Of the areas examined no discrepancies were note No violations or deviations were identifie Common Enclosure The inspector examined a sample of circuits required for safe shutdown. The licensee demonstrated:

     *
     - That the reviewed circuits were protected electrically by buses,' circuit breakers or rela'ys and i   ,

4 -' That redundant safe shutdown circuits were not routed in common enclosures.

Of the areas examined no discrepancies were note Noviolation'sordeviationslEereidentifi[d.,v,<4-

        '
       . ..  . .
          .

f_,

Communications "" - t -

jl o

         ,
            .
         ,  . m- _
    ~  ~
    ' The licensee demonstratedito.the inspectors,thatLthe'Ran~cho'Seco
       ~

communications system provided satisfactory redundancy ,to Jsupport the necessary communications.during a# firer No-discrepancies were note s # ' ' /, - , .

           '
        , .. ~

Noviolationsordeviations~wereidentihied.3,7' f

       -
           ,, -
          , Compliance with Sections III.G.3 and IIICL. *    -
            / ,j
      -
        ;    . >
            .
       . ,

Where it is.not' possible or practical to meet the requireme'nts of Section III.G.2. of. Appendix R, alternative or dedicated shutdown ~ capability must be provided 'in accordance with sections' III.G.3 and III.L of Appendix Due to the' adequacy of separation and protection of redundant. saf ' shutdown-trains outside.the control room, the licensee ~provided' s = alternative shutdown capability for only one area (control room). -This capability is' independent of;the control room-and consists of a' remote shutdown panel; local o-generators and reactor coolant

      /perations for the charging  system, diesel

_ system; and,, local operation of various '

    ' valves and circuit breakers'.
        ~

Alternative' shutdown capability is provided for one division of safe Eshutdown systems (Train A). Train "A"'is electrically isolated from the control room. Disconnect / transfer switches are provided .on Train "A" .

.
    +

s ,

-~----a__..------a- - _ _ . - - - - . _ - - - --___-    - --w  - - - , - . . s   .--s.-a- L w- -ueu.-- e-- - - --- -:-

.

'

which are properly designed to provide true isolation as is discussed in Information Notice No. 85-09. Given a control room fire that damages both redundant safe shutdown trains inside the control room, Train "B" could be lost in the control roo Because of the electrical isolation features, the disconnect / transfer switches provided. Train "A" would be used to mitigate the consequences of circuit failures inside the control room and enable. local control of equipment required for hot shutdown from the remote shutdown panel and other local control station The remote shutdown panel provides the capability to control the auxiliary feedwater system including atmospheric dump valve Instrumentation monitoring pressurizer pressure and level, reactor coolant system hot and cold leg temperatures, steam generator pressure and level is provided. Auxiliary feedwater flow and condensate storage tank level is provided locally. The control room alternative shutdown capability was determined to be satisfactory. The details are discussed belo No violations or deviations were identifie (1) Hot Shutdown Procedures .-

    *
    ,
    '

u. r  ;, Based on the control room' alternative shutdown methodology'used by the licensee, procedures havg been developed and, implemented (Procedure No. C13A dated July 85) in.accordance with Section II of Appendix < a .

-The inspectors evaluated tlie' procedure to~ verify the feasibility of required operator actions :that ' provide control of> p'rocess variables such as reactivity control, react'or coolant makeup, decay beat removal, process monitoring.and support functions when.offsite power is available and when offsite, power is unavailabl s  4 The procedure review resulted ih the inspectors concluding that the performa~nce goals for the shutdown functions could be met within the
-

minimum threshold criteria specified in the FSAR, SER and plant technical _ specifications and that required operator actions were achievabl To verify the effectiveness of the procedure, a walkdown of the procedure was conducted by the inspectors and the licensee's staff during the inspection. The licensee provided additional operations personnel to demonstrate the required operator actions. Therefore, normal plant operations were not interrupted during this activit The walkdown demonstrated that disconnect / transfer controls, control - switches', circuit breakers, manually operated valves and other equipment required'for safe shutdown were accessible and properly identified. All operations were determined to be feasible and i appeared that plant operators could accomplish them without-difficulty. The operations personnel who participated in the-demonstration were competent and knowledgeable of the required operator action ,

    ,
-
   .
,

m , .

-

7, .

    '_
   -( ;   .
      +
     '
   ,, .,Ls , < -
     '
      ~

No violations or deviations were' identified.~ ,

     *
(2) Cold Shutdown Procedures _
    , ,'
      '

The operator actions required to achieve and maintain; cold shutdown conditions for the control-room fire are contained in procedure C13B dated July 1985. The procedure as written will accomplish the goals

    '

required by Appendix The licensee has requested an exemption to the 72-hour cold shutdown required by Section III.L of Appendix The NRR systems reviewer stated that this was needed for the Rancho Seco reactor design and anticipated no difficulty in this area. The exemption request (see, paragraph 3.g) had not been formally approve The licensee had not yet determined the necessity of the Boric Acid pumps for cold shutdown. This is addressed in paragraph No violations or deviations were identifie (3) Manpower Requirements The licensee demonstrated that the fire brigade could be manned concurrent with performing the safe shutdown procedures as required by Appendix R Section II No violations or deviations were identifie (4) Training The inspector verified that adequate training had been performed by the personnel required to perform the safe shutdown procedure No violations or deviations were identifie . Compliance with Section III.J, Emergency Lighting The emergency lighting was examined to determine compliance with Appendix R Section II hour battery powered lights were provided in all areas required for safe shutdown and in the access and egress routes

'theret No violations or deviations were identifie . -Compliance with Section III.0 - Reactor Coolant Pump Oil Collection System-The lube oil collection system for the reactor coolant pumps was examined for compliance with the requirements of 10 CFR 50 Appendix R Section Rancho Seco provided a lube oil collection system for the non-welded joints that will collect oil from leakage during normal or accident-conditions of after-a safe shutdown' earthquake. -The system consist of

. two tanks each collecting the leakage from two pumps. Each tank has capacity above the volume of one reactor coolant; pump oil system. Each

  -

i .r r Y $'

          - -
    ~ _ ,. .
-  .        >
.

c'

  '
'

8~,

       ,

tank is closed and vented. An exemption request is pending NRR review of-the system capacity (see-paragraph 3.m).

~ No violations.or deviations were identifie ' Corridor to Elevation 47 (Fire Area 47)

.
'

By letter dated March 17, 1981, the licensee requested exemption from

 .Section III.G.2 of Appendix R to 10 CFR 50 to the extent that it requires the installation of an automatic fire suppression system in a fire area that contains redundant safe shutdown components. By letter dated January 10, 1983, NRR granted the licensee's request for exemption in Fire Area 4 '
  'In the evaluation, NRR. stated that the fire area is separated from other
'

plant areas by 3-hour fire rated barriers. During our site audit, the license'e informed the team that four undampered ducts pass through Fire . Area 47 and, therefore, the area is not separated from other plant areas

by 3-hour fire rated barriers. Moreover, the licensee's March 17, 1981 letter does not state that Fire Area-47 is separated from other plant areas by 3-hour fire rated barrier During the site audit, the NRR CMEB reviewer walked down Fire Area 47 and r the surrounding areas and reviewed the licensee's nonrated penetration analysis, which was available on sit Based on his review of the analysis-and walkdown, he concluded that-the

 . safety evaluation of the exemption request in the January 10, 1983 letter

' does not change. The exemption from Section III.G.2 of Appendix R to 10

  'CFR 50 for Fire Area .47 is, therefore, still valid.

, No violations or deviations were identifie ' Fire Pr'otection Program The inspection team reviewe'd the revised Rancho Seco fire protection

'

r-

"
 . program. :The licensee had revised his program to ensure that, as changes are.made.to plant systems and structures, the FHA will be kept updated.

. The lic'ensee also' increased-his program staffing and re-designated a number of responsibilitie ~ The revised plan appeared to be adequate to ensure that licensee fire protection program will be' implemented and. maintained.' i -

 ~

- No violations or deviations were identified.

10. Administrative Procedures .

        ~

To implement the revised fire protec ion' plan the 1icensee revised a number of.:his' administrative procedures. :The-l'nspector reviewed' these requirements against BTP.ASB 9.5.1. -1The inspector!found no areas where , the licensee did..not. comply with,his previous l commitments'. . . 4 , # NoviolationsordeviationsweEe%entilied.,2[['[',

    -
    . .    . E, f'     A w _ oo, c &  " )-
       ~
  ' *   ~
     '
    . ,  a
       ' .
. .r,    y: g .
      .

r -m ;

 ,s         " '
 ,  ,   .\-
     "
   '
       '
      '- t a  ?I ,
          '
         *
.-
  ,

_& $* , p ,

         -w U.'     '

ij .3--

       '
       . . -

, ~
 . _ .  - ,
        ,.   ._ .. . .-___ _ . . . . . _
     '
;  .
    -
      ,  ;e'  ?; e
:
:
.-

9; .-y; 6, ,

         ,
        ,
..
  --
 . 4        ,  ,

, , u x - _

      .      .

l

^

_

   ._
      ,   +
      '

' 17 11. -Plant-Touri _

      '  -*
,

r . , .

. . Housekeeping

[ - The housekeeping in the plant appeared to be in good orde I E x ., Combustibles were controlled and not allowed to accumulate to unsafe

 '   ~1evels.-

i,  ; , No violations or deviations were identifie .

  ' : Equipment s
             :

i Fire protection' systems and equipment appeared.to be in good working l

             !

condition and to be well maintained. Fire extinguishers were in-

pla'ce and had'their current inspection tags attached. Fire doors

    ~

p- appeared to- be operable and well maintaine ~ f, No violations /or deviations were identifie . Followup on'0 pen Items

  . (84-22-03) (Closed), 84-19-12 (Closed) Fire Protection Program

+ The-licensee revised his administrative procedures to incorporate

     ~
   -

all fire' protection commitment No' violations or deviations were identified.

I

(Closed), 84-22-04 (Closed), 84 22-05 (Closed) Improper Housekeeping and Storage

. . Th'e revised fire protection program appears to incorporate adequate , controls to' prevent' recurrence of these housekeeping items. During '

             ,

,. this inspection no deficiencies were noted.

! No violations or deviations were identifie . 4 .84 22-01 (Closed),' 84-22-02-(Closed) Trainin . During the inspection these items were noted to-have been correcte ~ Licensee action taken; prevent recurrence appears adequat '

   .No violations or deviations were identifie l

. ' ' ,;84-22-06 (Closed) Fir'e Doors

'
  -  .During the inspection-the.operabilityiof' fire doors-was examine .
          .
   'No problems were note '  '
     '
         ( ,
         . >
            ~
        ,
          '
 ,   No violations or deviations -were identified.

'

 *
  - cIN-851 09 (Closed)LI solation Transfer Switch and Post Fire Shutdo'wn

[ l Capabilit : . cf , ,' .

          '

_r

      ;  *

y + -p.

'

      ,c    , &F ,- -
         '  #

x -

     '
      ' ,.[
       - 2
        .g    ,

s. - s

           '
      '

, _ _ v r, } j

           ;' .
            <

g u.'

.
        ,

s

     ; .   * y? :e * ,~.m   %

i . .. . s z m _

           ,

_ _ - _ _ ,

i

 ,. x : -
   - -
                   .
>. . .
. s<
  , -
   ,      .

10 . .n <, _ f

,

_ The' safe. shutdown circuitry was examined to ensure that a control room! fire would not disable any, equipment that is needed to shut the

'
    . plant down from the remote shutdown panel .
  
%    > 'No violations,or deviations were identifie '
  ~1 Exit Meeting
.-
        .,..
   . An exit meeting was held with members of-licensee staff on August 16,
      -

1985. The items mentioned in this report were discussed at that tim , b

           -

T

     .,

k* Y a

O b

            %:3 ,
         (, ,.

7 ; ' < , . >-

                ,

s

         , -  ,
            , ,

4 , , ,

        -

7_-

             > -

e 5+ Y

         -  -  , s    .c e  o
           -      Y
       . g'
        '

91 e i j ~ / .; 04 ', p S

        '. ,  L
          ,.
           '
           ? .$
           ?,
            -
            .b. G
            , . .

m % '

              , e,* " s*_ _ ,

v a D4 ~ * n

          ,,/'
           -4 w 4
           $
                 '
           *
             * Af   'k

_ _ re, a.e%~ .

       -  . g
         '

y?

            ~
              ., s' *
               " x"
                *

g ,. .['

          *

e s , m. ,

              "3
  '
        . .  /  t 4 . -  .' J.-
              : ~

P^ ., eI" ~ !,$., , , .

                 "
              >  a ,,
        .,  . < -_     - , . ,

f ' p '

              ' $. m g r_       -

we r . r - ,

 ,      ,
         . .

y s $ _ * t r b' ' S t V ' , s 44 F ,

             '
  ,'    w 4 -

 .

_hk v

                  $
  =     g
.

-

   -

                  (

I L  % 4 s P _

^     1
 ,!j_ . _

_

     ,              .
 . -
     ;g -
        -        -

a y

       'n
  '                '
 '      ?
     <
      ,_
:   . .   . . - . ~ .
      '
       *

s s

,,a.m_
     ,
>

}}